I Received a Demand Letter for an Overpayment

Published 01/04/2021

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Brief Description
Palmetto GBA is pleased to offer secure and fast delivery of Railroad Medicare overpayment letters through our eServices self-service internet portal.
Initial demand letters and electronic remittance advice notices contain patient specific information.
Medicare’s Common Working File (CWF) system detects erroneous billings when there are two new patient CPT codes being billed within a three-year period of time by the same physician or physician group.
Providers have the option to submit payment for any overpayment determined by Medicare. Providers are strongly encouraged to submit electronic payments through eCheck, but may still mail a hard copy check.
A provider can elect to waive the standard grace days before offset begins on their overpayment and request immediate offset. The benefit of this option is it can reduce or eliminate the amount of interest assessed. If recoupment of the overpayment is satisfied within 30 days, no interest is charged. If a balance remains outstanding after 30 days, interest will be assessed on the outstanding balance for each 30-day period where a balance remains outstanding on the overpayment.
Overpayments will begin to recoup 40 days from the date of the demand letter. Billing providers should consider the status of their claims when determining if payment should be submitted or allow recoupment to take place.
Providers do not need to do anything to request standard recoupment after receiving a demand letter. Recoupment will begin automatically in accordance with the timeframe outlined in the demand letter received. Interest will accrue on the outstanding principal balance of the debt for each 30-day period in which a balance remains.
If an outstanding balance remains on an overpayment in an eligible collection status, a final demand letter will be issued and the debt may be referred to the Department of Treasury for collection.
A provider may submit a rebuttal statement within 15 calendar days from the date of the demand letter. The rebuttal statement must include an explanation or evidence to show why recoupment should not be initiated. A rebuttal submission is not considered an appeal and therefore does not stop recoupment upon receipt or while the request is reviewed. A rebuttal is not intended to review supporting medical documentation or disagreement with the overpayment decision.
If a provider disagrees with an overpayment determination made by Palmetto GBA, CERT, Recovery Auditor, or the ZPIC/UPIC, they may dispute the overpayment and stop the recoupment process by submitting a timely and valid appeal request. To ensure recoupment is timely stopped, a valid appeal must be received within 30 days of the date of demand letter for redetermination requests or within 60 days of the date of the revised demand letter for reconsideration requests. Please note recoupment does not cease when the appeal is at the ALJ and above level.
Providers may need more than 30 days to repay the full amount of an overpayment. Providers have the option to submit a Request For Extended Repayment Schedule (ERS). A complete ERS request should be submitted immediately.

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